USDA Comments

There’s power in numbers. Please drop your comments on the regs here (please start with listing category for each of your comments) and I’ll compile them into a unified document. Once the comments start to trickle down in a week or two, I’ll post the draft and a mechanism for ‘signing’ the letter. Then it will be submitted to USDA.

If you just wish to be included in the signing process, with or without leaving a comment, please DM me with the subject “cosigner” and your email address.

Please be thoughtful, remember who your audience is (regulators, general public, lay persons), and represent 4200 well.

This will be a consensus letter, meaning the final letter will include only those comments receiving an 80% ‘yes’ during the signing process. You can certainly submit your comments independently, but having a unified voice and being able to say that it is a consensus letter along with the list of signatories carrys a lot of weight with congress and the regulators.

*Total THC / limits
*Testing Procedure - sample collection, gc/hplc, MU
*Testing Time
*Licensure Qualifications
*L2L Product Sales/Transfers (Biomass)
*L2L Product Sales/Transfers (non-biomass extracts etc)
*Finished goods for sale to general public / businesses (no license for buyer)
*Fiber crops & products
*Seed crops & products
*waste biomass
*certified seed
*mobile operations
*manufacturing processes
*law enforcement / roadside issues
*cGMP / process sanitation / GACP


To whom it may concern at the USDA,

As a group of industry professionals, we at have put together our combined thoughts on your latest proposed hemp rules.

While we understand the perceived need for regulation, we have serious concerns with portions of the draft.

(List concerns)
(List solutions)

Thank you for upholding your democratic responsibilities and including the public in this important decision making process,

(Insert Name)


*Total THC

Hey everybody, I thought I had a good point here and wanted to get it out. I’ve never written for lawmakers before, so if anyone wants to edit this and make the point stand out enough for a thick headed politician to understand, please do edit it for us.

Saying that THCA contains 87% THC by weight would be like saying ethanol contains 70% methanol by weight. Will the alcoholic beverages industry be required to test or label products for “total methanol content”? Of course not, and it is equally non sensical that this type of regulation would be imposed on any other industry.

The current proposal calls for a total THC testing method that employs chemical reactions (heat catalyzed decarboxylation) to convert non THC molecules into the actual substance that is being tested for, THC.
However, this proposed decarboxylating testing method is not the only way to produce THC from non THC substances found in hemp. Lawmakers should be aware that CBD in particular is also converted to THC by a simple chemical reaction and therefore, to be consistent and have regulations that employ good science; CBD should be included in the “total potential THC” calculation formula at the rate of weight change when CBD is converted to THC.

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THC-A does not “contain” D9thc. When you burn or heat thc-a it changes into D9 ,with about 13% weight loss. The problem is in the way test results are interpreted.

And what are the actual yeilds when it’s burned? Alot of that THCA is destroyed or otherwise unavailable as d9. That 87% I’m sure is much lower when measured from an actual burning joint

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im not sure. I think they base it on general chemistry. a molecule THC-a weighs X, when you decarboxilate that molecule it weighs X times 0.87. Actual availability i could only guess.

The problem still remains that one agency looks at a test result and says its hot, another agency sees the same test results and says its ok. No one has agreed yet on D9 as tested or "potential’’ D9.

I feel like the whole idea of testing “potential” anything from a regulatory standpoint is just bad science. If I had a block of carbon and a bottle of air and put them together using chemical reactions I could “potentially” have a shitpotload of various regulated substances, right? What’s next if they start with this?



This bullshit justification on why hemp ever went out of favor in the first place. They conveniently left out the racism, and synthetic rope.

While hemp was produced previously in the U.S. for hundreds of years, its usage diminished in favor of alternatives. Hemp fiber, for instance, which had been used to make rope and clothing, was replaced by less expensive jute and abaca imported from Asia. Ropes made from these materials were lighter and more buoyant, and more resistant to salt water than hemp rope, which required tarring. Improvements in technology further contributed to the decline in hemp usage. The cotton gin, for example, eased the harvesting of cotton, which replaced hemp in the manufacture of textiles.

whom it may concern at the USDA,

While we understand the perceived need for regulation, we have serious concerns with portions of the draft.
*total THC/limits

i believe this whole thing should start with we need a universal standard for testing of the major cannabinoids; moreover Without reliable know benchmarks that are repeatable how does one lab to the next even test what .3% of anything is.

The cost of this needs to be cheap and widely available. if the labs are government facilities this will greatly increase the government’s overhead and inpead commerce. if for some reason the government shuts down this stops farmers from harvesting their fields , billions in revenue could be lost

I have heard other people suggest raising the thc D9 content to 1% , i feel even at 5% it should still be considered hemp.This will allow for a much more diverse and quality product , a much larger range of uses, more rare cannabinoids and thus creating more revenue for the state.

The advantages of hemp Vs paper are staggering so please make this as easy as possible for more hemp products to be made, reduce regulation and allow for free commerce. Allow smaller farms to thrive and give america back to the farmers


I highly doubt the USDA is going to budge on this, but it would still be good to have a concerted effort to try to pressure them to reconsider. We should also be contacting senators and congress members with sympathy for farmers/local economies and pull in DC, especially in States like CO and OR that forged the path and have a deeper understanding of the impact these new rules will have.

IMO they are purposely doing it to force hemp farmers more into the true industrial commodity fronts (fiber, hemp seed, hemp seed oil etc) in order to catch up with China and Canada of which we are importing these products from. That and they really don’t give a shit about the health of the people, been allowing (encouraging?) the poisoning of the populace for decades. Can’t wait to see what the FDA has in store. All decisions heavily influenced by lobbyist and the old money club. Putting new money in the pockets of small business and providing healthy products to consumers is frowned upon and never seems to work out well in the end, queue nicotine vaping.

Another wildcard option to put pressure on the USDA is a White House petition requesting executive action if the USDA does not do what is right. Regardless of what you think of him, Trump does care about jobs, boosting our economy and beating China - even if it just to stoke his ego and help him get re-elected. The USDA rules would devestate countless farmers, kill jobs, and stimy the rural economies that the 2014/2018 farm bills helped boost. Further it would encourage other Countries to take the lead in the burgeoning multibillion CBD market. A well layed out petition could reach the Presidents ear and I believe he does care about these particular issues. Needs at least 100k signatures to make a wave and reach Trumps desk.

Lastly does anyone know if individual States have the ability to override specific USDA reg details? Not sure, but it could be the last option, especially in early States that have hard data on the economic benefit.


You guys in legal states with legit labs will do great however this all turns out. Remediation, isolation, conversion whatever. In New York we have the right to buy diluted garbage from Cuomos 5 hand picked companies or risk prison time to produce quality for personal use medicine.
I agree with you all that testing is a real concern, piss testing that is.

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Why is there not more discussion on this? Banking on CBG is not the answer. If you grow it they will come? Hope so, but probably not.

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The only way any regulators will budge is if the people (in this case, the industry) make their voices heard. What you said should be directed at Trump himself is exactly what we need the USDA to hear. It needs to be directed at them. I agree with talking to your state reps - they have the ability to boost the industry’s voice. I’m pretty sure Oregon is already trying to work with the USDA to create a manageable hemp program, but Oregon’s own hemp rules are relatively strict as it is, so I wouldn’t count on them to fight for less regulation. It is possible for us to find a balance between too much regulation and not enough regulation, no matter how long it takes. If the voices for change aren’t loud enough though, bureaucrats who don’t know anything about hemp will be creating the rules.

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Sound familiar :joy:

What do you mean?

:heavy_check_mark::sunglasses: you called it. @BrotanicalMatt

@RiverleafBiotech your comment echoed a conversation we had earlier this week.

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Agreed, I was just saying a White House petition may be a last resort long shot option if the USDA does not budge. How exactly does the industry unite with a unified voice? Is there no Hemp/CBD consumer/farming organization in place (like the nicotine vaping industry has with CASSA)? If not, then someone (or everyone) needs to step up to lead the effort.


This is it. Right here. There’s more intellectual capital floating around on this forum than anywhere else in the industry, save for siloed pharma companies. Policy makers love to make data driven decisions. If we back our concerns/solutions proposed in this consensus letter with data, regulators will listen.


The Tennessee Hemp Industry Association is the most prominent state chapter. They have declared war on this proposal. Our president is scheduled to report to the membership after attending the national convention in a few days.